# APPENDIX E Dalton Hydro, LLC Operating Permit RACT provisions

OP-04-020 Issued onJune25, 2004 Only portions highlighted are intended for inclusion in the SIP. Strikeout text is not intended for inclusion in SIP.Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill

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## FINDINGS OF FAC



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Gempany at their request.

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/ ° \ PRIOR APPROVALSDalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020

(D) PERMIT

~APPLICABILITY

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Reguiatl9f?SDcrmit to Operate .

rmaGilfty Allowable Emissions, tonslyear

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### PERMIT CONDITIONS Construction and Equipment Specifications

Operating Limits (2) The sulfur content of any fuel 6it combusted in any~fue[ burning equip shall not exceed 2.0°lo'by weight. [1o vs:A. §5s6a(d)] (3) ent at the Facility The four (4) Babcock and Wilcox residual oil-fired boilers combined shall consume no 

### more than 495,900 gallons of residual oil, based on any rolling twelve (12) calendar month basis. [Administrative Order, January9,1996] (5) ?he Pomnittee shall properly operate and maintain itsfuel burning equipment in order to minimizi~ the generation of air contaminants: Proper operation of the Zurn wood: fired boiler'shall includethefoliowing: (a) the"~use of good operating pradices when handling, mixing; -arid regulating the wood fuel fed into the furnace section of the wood-fired boiler. The Permittee shall utilize only wood fuel uncontaminated by glixes, preservatives, oils or similar foreign substances. Furkhermore, the moisture conterit of the wood fuel shall not exceed sixty (60)percent by weight, ribishall the size of the wood being fired in the boiler ;eXCeed-t1IV41 (2) inches by five, .(5~'"inches. "(Administratfve Order, January 0, 1996] (b) timization of.the:'overfire arid underFire'air systemtohii,nimize the generation



### the-air cQritamin~h'ts carbon monoxide (CO"), and riitrbgen o xides (NOO

. The Permittee submitted r6oorts to the Agency on November 15; '1595 and Match 7, 1996 determining that the proper operating parameters for the Zurn wood-fired boiler at Meamloads betvveen 50,00UIb/hr and 90;000 Iblhr are : Oxy~e"ri : 6 .5 _'8.0 % Owerfire/UnderfireAir'Ratio*, ' 40/60to ?O/30 The PeriXiittee shall operate the Zurh wood-fired boiler within these limits to ensure continuous, compliance with the requirement to minimize the generation of COand NO,, [Administrative i~rder, Jan iuary9,~It996]Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020

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e e (15) Emissions of nitrogen oxides (NO,,) in the exhaust of the Zurn wood-fired boiler shall not exceed 0

.:3 Ibs1MMBTU and a mass discharge rate of_~54 Ibs/hr; These limits shall, ;be based on a rolling twenty-four;hour (24,- hour) average.J Gontink~ing compliance ,wit~ these limits shall be determined by the continuous emission monitoring systemrequired in Condition (22) of this Permit. This emission limit shall apply at all times except startup and shutdown. Emissions during periods of start-up and shutdown shall comply with Condition (24) of this Permit. [AdministrativeOrder, January a, 1sas] (16) Emissions of carbon monoxide (CO) in the exhaust of the Zurn wood-fired boiter shall not exceed 3.0 IbsIMMBTU and a mass discharge rateof 540 !bs/hr. These limits shall be based on a rolling 24 - hour average: Continuing compliance with these limits shall be determined by the,continuous emission monitoring systemrequired by Condition (22) of this Permit. This emission limit shall apply`e't aill times exceptstart-up and,shutdown. Emissions during pertvds of start-up and shutdoh shall comply with Condition (24) of this Permit" tAdministrative Order, January 8, 1998]

of the RpmDalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020
ComplianGe Testing

Continuous Emission Monitoring (22) `The Permittee shall install a Continuous Emission Monitoring System ("CEMS'°) to measure and permanently record nitrogivn , oxides, carbon monoxide, oxygen concentrations ;and stack gas -volurnetric flow rate from the Zurn wood-fired boiler exhaust and install a 'Continuous Opacity Monitor gystem ("COMS") to measure and permanently record thevisible emissions (opacity) fromthe heating plant exhaust. The Permittee shall operate and maintain such system in good working order and as specified below

: (a) , Within 184 days of initial permit issuartce, the COMS must be capable of operation .

irt compliance with this condition at an installation location that is dowrEstrearrifiromtheexhaust oft}~e Zurnwood=fired' boiler andfour (4) oil boilers and is re'preseir~tative of thetotal emissionsfromall heating plant boilers. (b) The CEMS and COM8 must be I operated 'continuously_and recarding ; valid data during` all periods of boiler;operation including'those periods of boiler startup, shutdown and malfunction; except for periods of CEMS and/or dCUMS Quality Control/Quality Assurance ("QA") identified- in the approved QA Plan, CEMS and/or COMS routine maintenance, or CEMS and/or COMS uncontrolled malfunction. Nevertheless, the Permittee must obtain valid CEMS and COMS data for all parameters for a minimumof 90°l0 of the operating hours, based on the calendarquarter. (c) The CEMS and COMS shall be installed, calibrated, maintained and operated according, to the Manufacturer's recommendations and in such a manner as to meet the requirements of 40 CFR, Part 60, Subpart A, 60.13, Appendix B,Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 Performance Specifications 1, 2, 3, 4 and- 6, 40 GFR, Part 60, 'Appendix F, Quality Assurance Procedures; and.- the "Continuous 11Emission M©nitoring Requirements" 0

;the ,Vermont Air Pollution Control ©ivisiori,'Technical Services Section (°TS'S") . (d) The Permittee shall develop, impIprYtetit ;and maintain a Quality Assuhance Plan ("QA Plan") for the CEIVIS and COMS. The Permitteq shall submit a revised QA Pan to the TSS within 18,0 days of initia.l Permit issuance. Said -plan shall satisfact6rily document acceptable ' instrumentation, monitoring pro6edures, calibration procedures, QA/QC procedures, dMa,acquisition and handling and reporting procedures as required to demonstrate compliance with this Permit. The QA Plan shall also include any emission testing procedures required to determine CEMS relative accuracy. The Permittee shall reviewthe QA Plan at least once each year and shall revise and,update the QA.Plan as necessary, based on °tf~e results of this review, or at the request of the Secretary of the Agency of Natural Resources or at any other appr6priate time to accurately document CEMS and COIVIS operations. The°Permittee shall notify the, TS$ in writing of the,results of the annuaf QAPlan review . All QAPlan modifications are subject to_TS$reviewand shall not be implemented 'until the Permittee has received written approval fromthe TSS . (e) The Permittee shall submit 'a summary ; report for each calendar quarter, within thirty (34) days after the close ofthe quaiter, which meets the applicable TSS C EMRequirements and is in a format acceptable;3o the TSS . The report shall include at a minimum all opacity, nitrogen oxides, and carbon monoxide emissions in excess of the emissions standards specified in Conditions (8),(10),(15) ;~(16) and (24) of this ,Permit, a frequency distribution that summarizes all the data collected, a suim~mary of valid data capture and periods of CEMS downtime and invalid data and calibration and audit results. (f) CEMS data for nitrogen oxides and carbon monoxide shall be reported in units of Ibs/MMBTU aiid Ibs/hour both in terms of 24-hour rolling averages, calculated on an hourly basis. Reported, valid 24-hour rolling averages must contain valid CEMS data representing at least eighteen (18) hours out of the preceding 24- hour period. In addition, the Permittee shall report the quarterly maximumand average 1 - hour and 24 - hour average emissions of NOXand CO in units of Ibs/MMBtu and Ibs/hr. (g) The Permittee shall maintain a file of all information reported in the quarterly summaries and all other data, collected by the monitoring systems for at least five (5) years from the date of collection of such data or submission of such summaries. All data records for the monitoring systems shall be marked to show the times of both start-up and shutdown of the 2urnwood-fired boiler. (h) If, on the basis of the continuous emission monitoring required by this condition, it is determined that the visible, nitrogen oxides or carbon monoxide, emissions exceed the standards specified in this Permit, the Permittee shall, through the application of good engineering practices, immediately review the major operating systems in the Facility in an effort to determine whether any such system has malfunctioned and will undertake its, best efforts to rectify the malfunctions, if any.Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 [10V .S.A. §556e(d),andAdministrative Order, January9, 1996]

Start-Up and Shutdown - Zurn,W60d-Fired Boiler (23) For the purposes of this Permit, the following definitions shall apply: (a) "start-up" periods are those periods of time from~the initiation of wood firing in the Zurn~ boiler until the unit ~ reaches -steady-state operations (85-100% load conditions) . This period shall not -exceed eight (8) hours for a cold start-up, nor four (4) hours for a hot start=up . A cold `start-up shall be defined as a start-up when the boiler has been down for morethan 24- hours. (b) "shutdown" period shall not exceed four (4) hours from the moment the wood supply to the Zurribdiler is eliminated,~~[Administrativeorder, January9, 199s] (24) The Permittee shall operate the vi+ood-fired, boiler ~~d associat~d combustion air control system in a r'r'tianner, consistent' with best practicable air pollution control practices to minimize emissions during start-up and shutdown belowthe limits summarized below in Table 5, Start-Up and Shutdown Limits:



### Table,b: btart-u anaf~bnutaown LIMITS Parameter Limit NpX 1 54 Ibslhr (1- hour average) Co 110g lbs/hr (1 -hour average) Emissions in excess of the limits identified in Table 5during start-up or shutdown shall be considered a violation of this Permit. The nurt~iber of hours that the boiler operates in a start-up ,of shutdown mode shall not exceed fifteen (15) percent of the total annual operating~tiours, ofthe Zurnwood-fired boiler. [AdministrativeOrder, January 9, 1996]Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

### Malfuunctian Procedures (25) The Permittee shall:implement and maintain theymalfunction abatement plan submitted to the Agency on May 16, 1995, for those systems/operations that affect regulated emissionsfromtheZurn wood-fired boiler. Theplan shall be implemented whenever the Zurn wood-fired boiler suffers a malfunction or other breakdown occurs. The malfunction abatement plan shall contain at a minimumthefollowing: 

### (a) a complete preventive maintenance programincluding: (i) the identifiqation'of Individuals' or positions resporasible foe inspecting, maintaining, and repairing the wood: #ired, boiler system anda anciilary equipment; 

### (ii) a description of the components thatwill be insp ted and maintained; (iii) the frequency of inspection, maintenanceservices and repairs; and (iv) an identification and quantities of replacement parts for the wood-fired boiler that shall be maintained in inventory at the Facility for quick replacement; (b) an identification of the operating variables° that may be monitored in order to detect a malfunction or faiiure; the no 1, operatiryg range of these variables; a descriptionof the method of monitortng ~;ar surveillance procedures; and a description of the methods or prc~cedures fhait will be used to informoperating personnel of any malfunctions, including alarm systems, lights or other indicators; and (c) a description of the corrective procedures that will ,be taken in the event of a malfunction or failure an order to achieve compliance with the applicable limits as expeditiously as practicable but no longer th'an;the next boiler or process outage that would provide for an orderly repair or correction of,~the malfunction ©i " fifteen (15) days, whichever is the shorter time interval .;. . If it is anticipated that the malfunction,would continue for more than°fifteen ,(15) days, a case by case repair schedule will be established by .the .Secretary in conjunction with the Permittee. [Administrative Order, January9, 1996] (26) Any amendments to the malfunction abatement plan'shall be reviewed and approved by the Secretary prior to its use. If the amendments do not adequately carry out the objectives of Condition (25) above, the.Secretary shall disapprove the amendments, and shall state his/her ~feasons for this disapproval . Jhe Permittee shall submit to the Secretary for his/her approval amendments reflecting changes in any element of the plan required by Condition (25) of this pern-mit or amendments when requested by the Secretary. The malfunction abatement plan amendments 'shall be implemented within sixty (60) days of receipt of written notice of approval by the Secretary. [Administrative Order, January9, 1996 (27) If, for a period of four (4) hours or more, the wood-fired boiler discharges excessDalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 emissions that are caused by a ;malfunction .or breakdown of the wood-fired boiler systemor,its anciliai~equiprrtent; or other abnormal'conditions, the Permittee shall : (a) °vdrbaily;:notify theAgency of any such occurrence within 72 hours of becoming awai`eo"f theoccurrence as described below : (i) name and location of thefacility, (ii) ~ the nature and causeofthe excess emissions, (iii) the time when the excess emissionswere first observed, (iv) the expected duration, and (v) an estimated rate of emissions; (b) notify, the Secretary immediately when the corrective measures have been accomplished; (c) submit to the Secretary within 15 days after the notification required in Condition (27)(a) abovea written reportwhich includes: 

### ([) riarnearid location ofthe facility, (ii) identification oi- description of the components, processes and control devices involved in the excess emissions, 

### (iii)' the cause and nature ofthe event, (iv) ' date,' time and duration of the violation or the expected duration of the excess emission ifthe cause ofthe excess emissions has not been fixed, (v) , estimated quantity of pollutant emitted; (vi) steps taken to control the excess emissions andto prevent reoccurrences and, if the cause of the excess emission has not been fixed, steps planned to be taken, and (vii) anyother pertinent information requested by the Secretary. [Administrative Order, January 9, 1996]

Recordkeeping and Reporting 

### (29) The Permittee shall, maintain records of all fuel oil consumed in the four, (4) Babcock and Wilcox boilers, irt or'cler to ;demonstrate 

### , compliance with Conditiort° (3) of this Permit. [Adrrtiinistrative'dtder, January 9, 1996] .Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020

(34) The Permittee

. shall submit to the Agency every six months fromthe date of issuance of this Permit a report containing thefollowing information; [§5-405(l) ofthe Regulations] 

### (a) a summary of the gallons of gasoline delivered to the facility required to be recorded by Condition (31) of this Permit; (b) a summary of the gallons of fuel, oil, consumed by the Babcock and Wilcox boilers required to be recorded by Condition (29) ofthis Permit; and (c) VOCemission records required to be maintained byCondition (33) of this Permit;Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020
Boston, MA02203

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(40) Ail records of monitoring data,and support anformation'skiall be retained for a minimum of five (5) years fromthe date of sampling, measurement, or report. All data records for the monitoririg sysfems;shall be marked to show the times of both start=up and shutdown of the,, Zurn wood-fired boiler [§s-ao~(l), §5-1o15(a)(5) ; and §5,-1015(b) of the Regulations and Administrative Order,January9, 1996j]Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020

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